Code of Conduct

Our Commitment

JPN Advogados advises clients with technical excellence, business acumen, and the direct involvement of its partners in every engagement. This Code of Conduct sets out the principles that govern the firm’s dealings with clients, the market, regulatory authorities, and society at large. It conveys to all who engage with the firm the values that underpin its work.

Values That Guide Our Practice

The firm’s conduct rests on six core values. Depth: we study the context, the regulatory environment, the parties, and the consequences before recommending any course of action. Proximity: our partners work directly with every client. Foresight: we identify scenarios before they materialize. Technical Excellence: our standard of work is non-negotiable, from initial analysis to the final document. Accountability: we act with discretion and honor the trust placed in us. Results: every engagement is focused on the objectives agreed upon with the client.

Professional Independence

The firm practices law with technical autonomy and objectivity. Its recommendations reflect its best technical assessment of each matter. The professional independence of the firm and its members is preserved under all circumstances.

Client Relationships

The client relationship begins with clarity. The firm defines the scope, objectives, and terms of each engagement together with the client, and conducts the work with transparency from start to finish. The confidentiality of everything entrusted to the firm is a permanent duty that survives the conclusion of the engagement. What belongs to the client remains the client’s.

Confidentiality and Professional Secrecy

The protection of information entrusted to the firm is an obligation binding on all of its members. The firm observes the professional secrecy obligations set forth in the Statute of the Legal Profession and the Brazilian Bar Association (OAB) (Law No. 8,906/1994) and in the OAB Code of Ethics and Discipline. Access to client information is restricted to the members directly involved in each engagement, and the storage, transmission, and disposal of documents follow secure practices.

Integrity and Anti-Corruption

The firm maintains absolute integrity in its relationships with clients, counterparties, public officials, and authorities. All interactions are guided by transparency and respect for institutional independence. The firm complies with applicable legislation, in particular Law No. 12,846/2013 (the Brazilian Anti-Corruption Law, also known as the Clean Company Act). Offering or granting any improper advantage to public officials or third parties to influence decisions is incompatible with the firm’s practice.

Conflicts of Interest

Before accepting a new client or engagement, the firm conducts a conflict-of-interest check. The review takes into account current clients, the parties involved, and the interests at stake. Where an actual or potential conflict is identified, the firm takes appropriate measures to safeguard its clients’ interests and the integrity of its practice.

Conduct in the Securities Market

The firm’s practice in Corporate Law and Capital Markets, including before the Brazilian Securities and Exchange Commission (CVM), calls for rigorous standards of market integrity. The firm and its members preserve the confidentiality of information to which they have access by reason of their engagements. Trading in securities on the basis of material non-public information is prohibited under Article 27-D of Law No. 6,385/1976 and applicable CVM regulations. Information obtained in the course of professional practice is used exclusively for the purposes of the relevant engagement.

Personal Data Protection

The firm processes the personal data of clients, employees, and third parties in accordance with Law No. 13,709/2018 (the Brazilian General Data Protection Law, LGPD). The collection and use of data are limited to what is necessary to conduct engagements and operate the firm. The firm’s Privacy Policy describes in detail how personal data is processed through this website.

Institutional Communications

The firm’s communications follow a standard of clarity, sobriety, and technical rigor. The firm’s content — including articles, legal opinions, and participation in industry events — reflects its accumulated experience and contributes to legal and regulatory debate, always with due regard for professional secrecy and clients’ interests.

Respect for People

The firm fosters a professional environment built on cooperation, respect, and appreciation for its people. Internal and external relationships are conducted with civility and consideration.

Reporting of Conduct

The firm remains open to dialogue regarding compliance with this Code. Reports of potential breaches are treated confidentially and investigated promptly and diligently, with protection afforded to those who report in good faith.

Effectiveness and Review

This Code reflects JPN Advogados’ ongoing commitment to ethics and integrity. It is reviewed whenever relevant regulatory or institutional developments so require.